The Florida Office of Financial Regulation (“OFR”) has rejected a petition for a declaratory statement seeking confirmation that payment processing activity involving the receipt of funds and transmission of such funds does...more
A new proposed rulemaking (the “NPRM”) would lower the current $3,000 threshold for the applicability of the Bank Secrecy Act (“BSA”) Recordkeeping Rule and Travel Rule to $250 for covered funds transfers that begin or end...more
A recent federal district court ruling in a criminal anti-money laundering case suggests that the transmission of virtual currency on behalf of another person requires a state money transmission license—even if the state’s...more
One of the defining aspects of the payments revolution of the past few years—at least from a regulatory perspective—has been the question of whether a particular payments service is subject to regulation as money...more
As we enter 2020, the payments and money transmission regulatory landscape continues to evolve on a state-by-state basis. One key development to kick off the year is newly adopted regulations in Massachusetts affirming that...more
Last year, we noted that the Banking Department of the Vermont Department of Financial Regulation had taken the position that its money transmission law “does not exempt a payment processor or an agent of a payee from [money...more
The payments and money transmission regulatory landscape continues to evolve. A key new development is that Michigan has affirmed by legislation that “agent of a payee” transactions meeting certain criteria are not subject...more
As we have noted on multiple occasions, one of the most important questions in the non-bank payments revolution — at least from a regulatory perspective — is whether a particular payments service is subject to regulation as...more
The Banking Department of the Vermont Department of Financial Regulation (the “Banking Department”) recently entered into a consent order with a money transmission licensing applicant (the “Applicant”). The consent order...more
As we have noted previously, one of the defining aspects of the payments revolution of the past few years—at least from a regulatory perspective—has been the question of whether a particular payments service is subject to...more